B2B WATER retail - GAP SITES

A gap site is a property that is connected to water and/or wastewater services but is not correctly recorded within the non-household water market. As a result, the site may have no retailer assigned, incomplete market records, or in some cases no valid Supply Point Identifier (SPID).

In simple terms, the property exists physically and may be consuming services, but there is a gap in the market data or registration process.

Common causes include:

• New developments where registration was never completed.
• Subdivision of larger sites into multiple units.
• Redevelopment or demolition projects altering site layouts.
• Historical data migration errors dating back to market opening in 2017.
• Incorrect occupancy records.
• Metering or address mismatches.
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Gap sites are particularly common within industrial, logistics, commercial property and redevelopment portfolios.

Gap sites are typically discovered through:

• Occupiers noticing they have never received a water bill.
• Retailers identifying unregistered premises.
• Wholesalers carrying out data quality investigations.
• Property transactions, audits or due diligence exercises.

1. Investigation

The wholesaler will establish:

• Whether the property is connected.
• Whether it is occupied.
• Whether water and wastewater services are being used.
• Meter details and site configuration.

Evidence may include meter readings, tenancy agreements, site plans and photographs.

2. Record Correction

The wholesaler will create or amend the SPID and correct any market data issues.

3. Retailer Allocation

A retailer is assigned to the site and the market records are updated.

4. Market Registration

The property becomes fully registered within the market and normal billing arrangements commence.

5. Historic Charges

Where services have been used but not billed, retrospective charges may be raised based on actual or estimated consumption and verified occupancy dates.

If your property is identified as a gap site, you should expect:

• Requests for occupancy and tenancy information.
• Requests for current meter readings.
• Investigation of historical consumption.
• Potential back-billing for previous periods.
• A process that may take several weeks or months to resolve.

It is important to note that discovering a gap site does not usually mean services were free of charge. Charges are often recovered once the site is correctly registered.

If you believe a property may be a gap site:

1. Identify the relevant wholesaler.
2. Confirm whether a valid SPID exists.
3. Record current meter readings immediately.
4. Gather evidence of occupancy dates.
5. Review wastewater charging assumptions.
6. Challenge any unreasonable estimated consumption.
7. Ensure the site is correctly registered going forward.

For property owners, investors and developers, gap sites can represent both risk and opportunity. They can lead to unexpected historic liabilities, but they can also uncover billing errors, incorrect occupier allocations and opportunities to recover historic overcharges. 

Early identification and resolution of gap sites is therefore an important part of utility due diligence and property portfolio management.